Question # 314

314. If a covered facility manufactures 19,000 pounds, processes 18,000 pounds, and imports 7,000 pounds of toxic chemical X (a non-PBT chemical) during the reporting year, is it required to report for toxic chemical X?
Yes. For the reporting year, the facility would have to report for toxic chemical X because it would have exceeded the manufacture threshold of 25,000 pounds (19,000 (manufactured) + 7,000 (imported) = 26,000). Note that importing constitutes manufacturing, and therefore, the amounts must be added together for threshold determinations.